es v. Bilzerian, 926 F.2d 1285, 1292 (2d Cir. 1991); Joy v. North, 692 F.2d 880, 893-94 (2d Cir. 1982); Teachers Ins. & Annuity Assin of America v. Shamrock Broadcasting Co., 521 F.Supp. 638 (S.D.N.Y. 1981). 2 As Ms. Maxwell previously pointed out, another of BSFs clients confessed to creating a fake "diary" to sell to